Anti Corruption Policy:

Executive Summary:

Employees and other personnel who work on behalf of TFW Printers Limited may be
exposed to corrupt behaviours where they work: for example offers of, or requests
for bribes, facilitation payments or grease payments.  TFW Printers Limited has a zero
tolerance approach to corruption. This means that the giving or receiving of bribes in
any form either directly or by those who work on behalf of TFW  is prohibited and will not
be tolerated. Bribery is a criminal offence in most countries. An increasing number of countries have
adopted laws to prohibit bribery even if it takes place outside of their borders. Under the
UK Bribery Act:

Individuals and companies will commit a criminal offence if they either give or receive a bribe and this includes bribery involving Public Officials or private  individuals/workers in the private sector; and If any persons Associated with the TFW pays a bribe (which includes facilitation payments) anywhere in the world, then TFW can be criminally liable.  Under the UK Bribery Act, those who  commit bribery could be liable to unlimited fines and prison sentences of up to 10 years.

The objective of this Standard is to define the actions that are required to be taken if an Employee or Other Personnel is subject to an offer of, or a request for, a bribe (including facilitation payments) or any other unethical approach while working for or on behalf of TFW Printers Limited.

Scope and Application:
This is a Personal Conduct Standard. Application of Personal Conduct Standards is mandatory for all TFW employees, consultants and other personnel working in controlled offices, and those seconded to nonccontrolled Joint Ventures.

For TFW employees, breach of this Standard may result in disciplinary action, up to and including dismissal. Breach of this Standard by any individual who is not a TFW employee may result in other appropriate action being taken in relation to the individual and/or the business which supplies services to TFW, including termination of the relevant contract(s).

This Standard is not contractual. TFW reserves the right to amend, suspend or terminate this Standard.

Standard Requirements
TFW employees and Other Personnel shall not offer, promise or make any payment or transfer anything of value, including
the provision of any service, money, gift or hospitality or any other advantage, to anybody (including Public Officials) for
the purpose of obtaining or retaining business or for any other improper purpose.

TFW Employees and Other Personnel shall not request, agree to receive or accept anything of value, including the provision of any service, money, gift or hospitality or any other advantage for an improper purpose or improper performance of an activity.

TFW Employees and Other Personnel shall make themselves aware of;
(i) the relevant bribery laws where they work and undertake anti-bribery training that is provided by TFW and;

(ii) the corruption risks where they work in order to understand where they may be subject to unethical approaches and to be prepared should this happen.

In the event that TFW Employees or Other Personnel are asked for a facilitation payment or requested for/offered a bribe, while carrying out duties for the TFW, it shall be politely refused stating that it would breach TFW policy and the law.

All offers of bribes, requests for bribes or facilitation payments and any payments shall be reported as soon as possible, using the form provided which should be sent to your TFW Compliance Officer.

TFW Employees and Other Personnel shall seek to incorporate anti-bribery provisions into all contracts with third parties.

TFW  Employees and Other Personnel shall use their influence with our contractors and Joint Venture partners to
(i) to implement adequate policies and procedures to prevent bribery and;

(ii) promote high ethical standards throughout the supply chain.